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Dutch Court Holds Brazilian Interest on Net Equity Should be Classified as Dividends

|Treaty Development|Netherlands-Brazil
Netherlands-Brazil

The Dutch District Court of Zeeland-West Brabant has issued a decision on the treatment of Brazilian interest on net equity (juros sobre o capital próprio - JCP) under the 1990 Brazil-Netherlands tax treaty. The case concerns a Dutch taxpayer that owned 99.97% of the shares in a Brazilian company. In 2018, the taxpayer received JCP payments from the company, which the tax authority classified …

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